Correspondence 0001741773-25-002199 from BNY MELLON FUNDS TRUST (CIK 0001111565)
BNY MELLON FUNDS TRUST (CIK 0001111565)
Date: May 27, 2025 · CIK: 0001111565 · Accession: 0001741773-25-002199
AI Filing Summary & Sentiment
File numbers found in text: 811-00523, 811-00524, 811-02192, 811-03081, 811-03207, 811-03721, 811-03757, 811-03940, 811-04765, 811-05202, 811-05245, 811-05454, 811-05652, 811-05877, 811-05883, 811-06325, 811-06377, 811-06490, 811-06718, 811-07123, 811-07512, 811-09891, 811-09903, 811-21236, 811-21327, 811-22912, 811-23477
Letter
Re: 408 SOX Review -- BNY Mellon Family of Funds Listed in Appendix A
May 27, 2025
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Megan F. Miller
Ladies and Gentlemen:
On behalf of the funds in the BNY Mellon Family of Funds listed in Appendix A hereto (each, a "Fund"), transmitted for filing as EDGAR correspondence are the Funds' responses to the comments of the accounting staff (the "Staff") of the Securities and Exchange Commission (the "Commission"), provided by Megan F. Miller, Staff Accountant, to the undersigned by telephone on February 26, 2025 and May 1, 2025. The Staff's comments related to the three-year review of the audited financial statements of the Funds for the fiscal years ended on the respective dates noted in Appendix A, included in the Funds' annual reports on Form N-CSR as filed with the Commission, pursuant to Rule 408(c) of the Sarbanes-Oxley Act of 2002.
Set forth below is a summary of the Staff's comments, and the Funds' responses thereto.
BNY Bond Market Index Fund
Comment 1: Please confirm that the disclosure for TBA investments aligns with Regulation S-X 6-07.7 (see AICPA Expert Panel Minutes, November 13, 2023).
Response 1: Fund management confirms that going forward realized and unrealized TBA will be broken out to align with Regulation S-X 6-07.7.
Comment 2: Please consider updating the disclosure for caption "Statement of Operations" to state securities lending income is presented net of any rebates or fees paid to Borrowers.
Response 2: Fund management confirms that going forward the Statement of Operations will state securities lending income net of any rebates or fees paid to Borrowers and will update applicable notes.
BNY Mellon Yield Enhancement Strategy Fund
Comment 3: Please confirm Financial Highlights include to the extent required a footnote stating that "Ratio of net investment income" does not reflect proportionate share of income of the Underlying Funds in which the Fund invests. (See ASC 946-205-50-16.)
Response 3: Included in the Items 7-11, "Annual Financials and Other Information" dated October 31, 2024, is a footnote that reads "excludes expenses of underlying funds", and such footnote will be included, as applicable, for the fund going forward.
BNY Mellon Natural Resources Fund
Comment 4: Please note, the S&P Global Natural Resources Index was incorrectly tagged in XBRL as the "broad based" index.
Response 4: Going forward, the broad-based index will be correctly tagged in XBRL. The order in which each index was disclosed was switched, which caused an inadvertent tagging error.
BNY Mellon Funds Trust – Municipal Funds
Comment 5: Please consider including a "Total'" for "accumulated earnings" in Table 1 -- Components of Accumulated Earnings.
Response 5: Going forward, the word "Total" will be included in Table 1, as requested.
Funds that Engage in Securities Lending
Comment 6: Please explain why securities lending income is not noted as "affiliate" on Statement of Operations.
Response 6 Going forward, securities lending income will include the word "affiliate", as requested.
All Relevant Funds
Comment 7: Please explain how Item 10 of N-CSR meets the requirement to disclose aggregate remuneration paid by the Company during the period covered by the report if payments are disclosed in multiple locations in Item 7 (e.g., Item 10 reflects payment to Trustees, Line 7 states payable to CCO) (See TSR FAQ No.3).
Response 7: For those Funds that have relevant payments disclosed in multiple locations in Item 7, Item 10 of N-CSR, the disclosure will be revised going forward to include the aggregate dollar amount of relevant remuneration paid by the Fund during the period covered by the report. Examples of the revised disclosure:
For Funds without unitary fee:
Each board member also serves as a board member of other funds in the BNY Mellon Family of Funds complex, and annual retainer fees and meeting attendance fees are allocated to each fund based on net assets. The fund is charged for services performed by the fund's Chief Compliance Officer. Compensation paid by the fund during the period to the board members and the Chief Compliance Officer are within Item 7. Statement of Operations as Directors'[/Trustees'] fees and expenses and Chief Compliance Officer fees, respectively. The aggregate amount of Directors'[/Trustees'] fees and expenses and Chief Compliance Officer fees paid by the fund during the period was $_____.
For Funds with unitary fee:
Each board member also serves as a board member of other funds in the BNY Mellon Family of Funds complex, and annual retainer fees and meeting attendance fees are allocated to each fund based on net assets. The Adviser reimburses the fund for the fees and expenses of the non-interested board members. Compensation paid by the fund to the board members and board member fees reimbursed by the Adviser during the period are within Item 7. Statement of Operations as Directors'[/Trustees'] fees and Directors'[/Trustees'] fees reimbursed by BNY Mellon Investment Adviser, Inc., respectively.
BNY Mellon Municipal Income and BNY Mellon Strategic Municipal Bond Fund
Comment 8: Please confirm that description of Debt in Notes to Financial Statements includes the effective interest rate in addition to the stated rate (See ASC 835-30-45-2).
Response 8: The description of debt in Note 1(e) includes the effective interest rate in addition to the stated rate.
All Relevant Funds
Comment 9: Please explain why overdraft fees are netted with interest income as opposed to an expense to the Fund (see Note in Statement of Operations). Specifically, the rationale for netting overdraft fees from interest income.
Response 9: Per the rule, expenses are only broken out if expenses exceeded 5% of total expenses or total income. The rationale for netting is because the amounts were immaterial.
Unitary Fee Funds
Comment 10: Please confirm what fees and expenses are excluded from the management fee (e.g., are loan commitment fees, interest expense and securities lending fees paid by the Fund).
Response 10: Fees and expenses excluded from the unitary management fee are: 12b-1 fees, if applicable, shareholder services fees, if applicable, loan commitment fee from borrowings and interest expense as well as any extraordinary expenses.
* * * * *
Should you have any questions or comments, please feel free to contact me at 212.540.4569 (dstephens@stradley.com) .
Very
truly yours,
/s/
DAVID STEPHENS
David Stephens
Show Raw Text
CORRESP
1
filename1.htm
May 27, 2025
VIA EDGAR
Securities
and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Megan F. Miller
Re: 408
SOX Review -- BNY Mellon Family of Funds Listed in Appendix A
Ladies and Gentlemen:
On
behalf of the funds in the BNY Mellon Family of Funds listed in Appendix A hereto (each, a "Fund"), transmitted
for filing as EDGAR correspondence are the Funds' responses to the comments of the accounting staff (the
"Staff") of the Securities and Exchange Commission (the "Commission"), provided by Megan F. Miller, Staff
Accountant, to the undersigned by telephone on February 26, 2025 and May 1, 2025. The Staff's comments
related to the three-year review of the audited financial statements of the Funds for the fiscal years
ended on the respective dates noted in Appendix A, included in the Funds' annual reports on Form N-CSR
as filed with the Commission, pursuant to Rule 408(c) of the Sarbanes-Oxley Act of 2002.
Set
forth below is a summary of the Staff's comments, and the Funds' responses thereto.
BNY
Bond Market Index Fund
Comment 1: Please
confirm that the disclosure for TBA investments aligns with Regulation S-X 6-07.7 (see AICPA Expert Panel
Minutes, November 13, 2023).
Response 1: Fund
management confirms that going forward realized and unrealized TBA will be broken out to align with Regulation
S-X 6-07.7.
Comment 2: Please
consider updating the disclosure for caption "Statement of Operations" to state securities lending income
is presented net of any rebates or fees paid to Borrowers.
Response 2: Fund
management confirms that going forward the Statement of Operations will state securities lending income
net of any rebates or fees paid to Borrowers and will update applicable notes.
BNY
Mellon Yield Enhancement Strategy Fund
Comment 3: Please
confirm Financial Highlights include to the extent required a footnote stating that "Ratio of net investment
income" does not reflect proportionate share of income of the Underlying Funds in which the Fund invests.
(See ASC 946-205-50-16.)
Response 3: Included
in the Items 7-11, "Annual Financials and Other Information" dated October 31, 2024, is a footnote that
reads "excludes expenses of underlying funds", and such footnote will be included, as applicable, for
the fund going forward.
BNY Mellon Natural Resources Fund
Comment
4:
Please note, the S&P Global Natural
Resources Index was incorrectly tagged in XBRL as the "broad based" index.
Response
4:
Going forward, the broad-based index will
be correctly tagged in XBRL. The order in which each index was disclosed was switched, which caused
an inadvertent tagging error.
BNY Mellon Funds Trust – Municipal
Funds
Comment
5:
Please consider including a "Total'" for
"accumulated earnings" in Table 1 -- Components of Accumulated Earnings.
Response 5:
Going forward, the word "Total" will be
included in Table 1, as requested.
Funds that Engage in Securities Lending
Comment
6:
Please explain why securities lending income
is not noted as "affiliate" on Statement of Operations.
Response 6 Going
forward, securities lending income will include the word "affiliate", as requested.
All
Relevant Funds
Comment 7: Please
explain how Item 10 of N-CSR meets the requirement to disclose aggregate remuneration paid by the Company
during the period covered by the report if payments are disclosed in multiple locations in Item 7 (e.g.,
Item 10 reflects payment to Trustees, Line 7 states payable to CCO) (See TSR FAQ No.3).
Response
7:
For those Funds that have relevant payments
disclosed in multiple locations in Item 7, Item 10 of N-CSR, the disclosure will be revised going forward
to include the aggregate dollar amount of relevant remuneration paid by the Fund during the period covered
by the report. Examples of the revised disclosure:
For
Funds without unitary fee:
Each board member also serves as a board
member of other funds in the BNY Mellon Family of Funds complex, and annual retainer fees and meeting
attendance fees are allocated to each fund based on net assets. The fund is charged for services performed
by the fund's Chief Compliance Officer. Compensation paid by the fund during the period to the board
members and the Chief Compliance Officer are within Item 7. Statement of Operations as Directors'[/Trustees']
fees and expenses and Chief Compliance Officer fees, respectively. The aggregate amount of Directors'[/Trustees']
fees and expenses and Chief Compliance Officer fees paid by the fund during the period was $_____.
For Funds with unitary fee:
Each
board member also serves as a board member of other funds in the BNY Mellon Family of Funds complex,
and annual retainer fees and meeting attendance fees are allocated to each fund based on net assets.
The Adviser reimburses the fund for the fees and expenses of the non-interested board members. Compensation
paid by the fund to the board members and board member fees reimbursed by the Adviser during the period
are within Item 7. Statement of Operations as Directors'[/Trustees'] fees and Directors'[/Trustees']
fees reimbursed by BNY Mellon Investment Adviser, Inc., respectively.
BNY
Mellon Municipal Income and BNY Mellon Strategic Municipal Bond Fund
Comment 8:
Please confirm that description of Debt
in Notes to Financial Statements includes the effective interest rate in addition to the stated rate
(See ASC 835-30-45-2).
Response 8: The
description of debt in Note 1(e) includes the effective interest rate in addition to the stated rate.
All Relevant Funds
Comment 9: Please
explain why overdraft fees are netted with interest income as opposed to an expense to the Fund (see
Note in Statement of Operations). Specifically, the rationale for netting overdraft fees from interest
income.
Response 9: Per
the rule, expenses are only broken out if expenses exceeded 5% of total expenses or total income. The
rationale for netting is because the amounts were immaterial.
Unitary Fee Funds
Comment
10:
Please confirm what fees and expenses are
excluded from the management fee (e.g., are loan commitment fees, interest expense and securities lending
fees paid by the Fund).
Response 10: Fees
and expenses excluded from the unitary management fee are: 12b-1 fees, if applicable, shareholder services
fees, if applicable, loan commitment fee from borrowings and interest expense as well as any extraordinary
expenses.
* * * * *
Should you have any
questions or comments, please feel free to contact me at 212.540.4569 (dstephens@stradley.com) .
Very
truly yours,
/s/
DAVID STEPHENS
David Stephens
cc: Sarah
Kelleher
Amanda Quinn
APPENDIX
A1
0000718935
811-03721
BNY
Mellon Intermediate Municipal Bond Fund, Inc.
S000000073
BNY Mellon Intermediate Municipal Bond Fund, Inc.
5/31/2024
0000875732
811-06325
BNY
MELLON MIDCAP INDEX FUND, INC.
S000000078
BNY
Mellon Midcap Index Fund, Inc.
10/31/2024
0000828475
811-05454
BNY
MELLON NEW JERSEY MUNICIPAL BOND FUND, INC.
S000000091
BNY
Mellon New Jersey Municipal Bond Fund, Inc.
12/31/2023
0000737520
811-03940
BNY
Mellon Strategic Funds, Inc.
S000000092
BNY
Mellon Active MidCap Fund
12/31/2023
0000797920
811-04765
BNY
MELLON NEW YORK AMT-FREE MUNICIPAL BOND FUND
S000000093
BNY
Mellon New York AMT-Free Municipal Bond Fund
11/30/2023
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000371
BNY
Mellon Small Cap Multi-Strategy Fund
8/31/2024
0000857114
811-05883
BNY
MELLON INDEX FUNDS, INC.
S000000130
BNY
Mellon International Stock Index Fund
10/31/2024
0001199348
811-21236
BNY
MELLON STOCK FUNDS
S000000354
BNY
Mellon International Core Equity Fund
9/30/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000362
BNY
Mellon Massachusetts Intermediate Municipal Bond Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000364
BNY
Mellon National Intermediate Municipal Bond Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000365
BNY
Mellon National Municipal Money Market Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000366
BNY
Mellon National Short-Term Municipal Bond Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000367
BNY
Mellon Pennsylvania Intermediate Municipal Bond Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000368
BNY
Mellon Short-Term U.S. Government Securities Fund
8/31/2024
0000914775
811-07123
BNY
Mellon Advantage Funds, Inc.
S000000498
BNY
Mellon Dynamic Value Fund
8/31/2024
BNY
Mellon Advantage
S000000500
BNY
Mellon Technology
8/31/2024
1
As provided by Megan F. Miller
of the Staff.
0000914775
811-07123
Funds,
Inc.
Growth
Fund
0000878092
811-06377
BNY
MELLON MUNICIPAL FUNDS, INC.
S000000330
BNY
Mellon AMT-Free Municipal Bond Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000369
BNY
Mellon Income Stock Fund
8/31/2024
0000353560
811-03207
GENERAL
MONEY MARKET FUND, INC.
S000000119
GENERAL
MONEY MARKET FUND, INC
11/30/2023
0000030167
811-02192
BNY
Mellon Sustainable U.S. Equity Fund, Inc.
S000000095
BNY
Mellon Sustainable U.S. Equity Fund, Inc.
5/31/2024
0000897569
811-07512
BNY
Mellon Worldwide Growth Fund, Inc.
S000000096
BNY
Mellon Worldwide Growth Fund, Inc.
10/31/2024
0000030146
811-00523
BNY
Mellon Large Cap Securities Fund, Inc.
S000000068
BNY
Mellon Large Cap Securities Fund, Inc.
12/31/2023
0000889169
811-06718
BNY
Mellon Investment Funds VII, Inc.
S000000297
BNY
Mellon Short Term Income Fund
7/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000370
BNY
Mellon Mid Cap Multi-Strategy Fund
8/31/2024
0000818972
811-05245
BNY
MELLON STRATEGIC MUNICIPALS, INC.
CEF0014552
BNY
MELLON STRATEGIC MUNICIPALS, INC.
9/30/2024
0000855887
811-05877
BNY
MELLON STRATEGIC MUNICIPAL BOND FUND, INC.
CEF0013739
BNY
MELLON STRATEGIC MUNICIPAL BOND FUND, INC.
11/30/2023
0000819940
811-05202
BNY
Mellon Investment Funds IV, Inc.
S000000299
BNY
Mellon Institutional S&P 500 Stock Index Fund
10/31/2024
0000819940
811-05202
BNY
Mellon Investment Funds IV, Inc.
S000000305
BNY
Mellon Tax Managed Growth Fund
10/31/2024
0000819940
811-05202
BNY
Mellon Investment Funds IV, Inc.
S000000307
BNY
Mellon Bond Market Index Fund
10/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000021515
BNY
Mellon New York Intermediate Tax-Exempt Bond Fund
8/31/2024
0000737520
811-03940
BNY
Mellon Strategic Funds, Inc.
S000015656
BNY
Mellon Global Stock Fund
11/30/2023
0000737520
811-03940
BNY
Mellon Strategic Funds, Inc.
S000015657
BNY
Mellon International Stock Fund
11/30/2023
0000878092
811-06377
BNY
MELLON MUNICIPAL FUNDS, INC.
S000002850
BNY
Mellon High Yield Municipal Bond Fund
8/31/2024
0001591556
811-22912
BNY
Mellon Investment Funds II, Inc.
S000043942
BNY
Mellon Global Emerging Markets Fund
10/31/2024
0000737520
811-03940
BNY
Mellon Strategic Funds, Inc.
S000029388
BNY
Mellon Select Managers Small Cap
5/31/2024
Growth
Fund
0000881773
811-06490
BNY
Mellon Investment Funds V, Inc.
S000019789
BNY
Mellon Large Cap Equity Fund
12/31/2023
0000881773
811-06490
BNY
Mellon Investment Funds V, Inc.
S000019790
BNY
Mellon Developed Markets Real Estate Securities Fund
10/31/2024
0000053808
811-00524
BNY
Mellon Investment Funds III
S000012565
BNY
Mellon Equity Income Fund
5/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000023621
BNY
Mellon Municipal Opportunities Fund
8/31/2024
0000857114
811-05883
BNY
MELLON INDEX FUNDS, INC.
S000000131
BNY
Mellon S&P 500 Index Fund
10/31/2024
0000857114
811-05883
BNY
MELLON INDEX FUNDS, INC.
S000000132
BNY
Mellon Smallcap Stock Index Fund
10/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000372
BNY
Mellon International Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000373
BNY
Mellon Emerging Markets Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000374
BNY
Mellon Asset Allocation Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000375
BNY
Mellon Bond Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000000376
BNY
Mellon Intermediate Bond Fund
8/31/2024
0000914775
811-07123
BNY
Mellon Advantage Funds, Inc.
S000000461
BNY
Mellon Opportunistic Midcap Value Fund
8/31/2024
0000914775
811-07123
BNY
Mellon Advantage Funds, Inc.
S000000462
BNY
Mellon Opportunistic Small Cap Fund
8/31/2024
0001111565
811-09903
BNY
MELLON FUNDS TRUST
S000035959
BNY
Mellon Corporate Bond Fund
8/31/2024
0000819940
811-05202
BNY
Mellon Investment Funds IV, Inc.
S000042108
BNY
Mellon Floating Rate Income Fund
8/31/2024
0000737520
811-03940
BNY
Mellon Strategic Funds, Inc.
S000024356
BNY
Mellon Select Managers Small Cap Value Fund
11/30/2023
0000318478
811-03081
BNY
MELLON APPRECIATION FUND, INC.
S000000008
BNY
Mellon Appreciation Fund, Inc.
12/31/2023
0000720064
811-03757
BNY
MELLON CALIFORNIA AMT-FREE MUNICIPAL BOND FUND, INC.
S000000016
BNY
Mellon California AMT-Free Municipal Bond Fund, Inc.
5/31/2024
0001493580
811-23477
BNY
Mellon ETF Trust
S000073736
BNY
Mellon Concentrated International ETF
10/31/2024
0000839122
811-05652
BNY
MELLON MUNICIPAL INCOME, INC.
CEF0014355
BNY
MELLON MUNICIPAL INCOME, INC.
9/30/2024
0001224568
811-21327
BNY
Mellon Investment Funds VI
S000000342
BNY
Mellon Balanced Opportunity Fund
11/30/2023
0001111178
811-09891
BNY
MELLON OPPORTUNITY FUNDS
S000001720
BNY
Mellon Natural Resources Fund
9/30/2024
0001591556
811-22912
BNY
Mellon Investment Funds II, Inc.
S000044141
BNY
Mellon Yield Enhancement Strategy Fund
10/31/2024
0000737520
811-03940
BNY
Mellon Strategic Funds, Inc.
S000022407
BNY
Mellon U.S. Equity Fund
11/30/2023